On 23 January 2019, the Personal Data Protection Commission (i.e. the Info-comm Media Development Authority) (the “PDPC”) published its Model Artificial Intelligence Governance Framework (“Model Framework”). The PDPC also launched a public consultation to receive feedback on the Model Framework.

As an organisation committed to thought leadership in law and technology (with AI regulation a key area of focus), LawTech.Asia produced a response to the public consultation on 24 June 2019.

LawTech.Asia’s response comprised the following two sections:

A framework tailored for the implementation of the Model Framework to the legal technology sectors. Tapping on LawTech.Asia’s familiarity with the legal and legal technology sectors, LawTech.Asia produced a customised framework tailored specifically for the implementation of the Model Framework to the legal technology industry. We hope that this customised framework may shed some light in allowing legal technology firms deploying AI to have greater guidance in aligning their practices with some of the implementation guidelines set out in the Model Framework.

Comments and feedback on each specific section covered by the Model Framework. These sections are, namely: the overall principles set out in the Model Framework, internal governance measures, determination of the AI decision-making model, operations management, and customer relations management. Tying our comments together is the thread that the Model Framework could go further in elaborating on some of the guidelines that it had set out, as well as to set out more specifically the ends that the Model Framework is targeted at achieving.